I recently was introduced to the Ammonia Gas Safety Blanket manufactured by Gas Safety Products LLC.
Dealing with ammonia and the potential to have a gas leak with any line opening this blanket could be very beneficial to safety for all involved. GCAP has requested theirs for show students how this tool works. The blanket itself is designed to be attached to a water hose, wrap the pipe, and let the ammonia gas absorb into the water.
For more information on the blanket contact:
Randy and Rachel Williams of GCAP went to the first ATMOsphere ASIA this week in Tokyo Japan.
Technology & Innovation: Having always been a pioneering advocate in the field of natural refrigerants, Japan is the ideal location for the first-ever ATMOsphere Asia Conference. This conference aims to support the uptake of leading natural refrigerant technologies from all over Asia by global markets and bring international suppliers to Asia. ATMOsphere Asia serves as a forum for exchanges between leading end-users, suppliers, academics and government representatives.
ATMOsphere America 2014 will be San Francisco. Look for GCAP to make this 3rd annual conference. 2013 Video Below.
Garden City Ammonia Program is proud to host the 6th Annual Ammonia Safety Day in Kansas City, KS. May 29,2014 at the Kansas City Community College. Event will be held in the basketball gym.
This year we will have topics on Emergency Response, Incidental Release, Ammonia Sensors, Control Valves, OSHA, and EPA.
Must be pre-registered to guarantee a seat. Last year we had over 225 attendees and 18 vendors. Hope to see you there this year.
$35.oo per attendee
$350.00 per vendor
$500.00 sponsorship for breakfast or lunch
Today’s PodCast, Jeremy Williams, Brian Chapin, and Josh Latovich of Garden City Ammonia Program talk about the top 3 questions asked in PSM courses through out the year. Usually many difficult question are asked during class, although some of the simplest questions may be the most difficult to implement.
PSM word for thought in 2013: If PSM training or process training is viewed only as an event, it will ultimately lead to failure of the program.
- How do we inform all employees that PSM exists?
- How do I organize my PSM program?
- What about PSM Software?
GCAP has had the privilege to be in many facilities for both training and compliance services. Please feel free to listen to today’s podcast addressing how we have seen it done best.
Thank you all for your support in 2013, We wish you all a Merry Christmas and a Happy New Year.
Don’t forget about the 2014 PSM/RMP Training Tour
GCAP is always looking to improve our PSM training program and consultation services. One of the tools we use is to request information from OSHA and the EPA under the Federal “Freedom of Information Act” which is often referred to as a FOIA request. In 2012 (at great expense) we used this tool to get the citation information for all PSM citations from 2008-2011. In 2013 we filed additional FOIA’s to get all 2012 citations. We don’t just get the citations themselves, but the documents behind them that show the reasoning behind the citations including pictures, the inspector’s inspection narrative, etc. Obviously, we learned a lot about how OSHA and the EPA interpret the PSM/RMP standards from these FOIA’s and we’ve used that information in our custom textbook for our PSM class as well as source/working material for our NEP class.
Earlier this year, due to a FOIA we read an inspector quote from OSHA course book “3430 – Advanced Process Safety Management in the Chemical Industries.” We’ve long known of this course, but it’s only available from the OSHA Training Institute and only allows OSHA inspectors to attend the class. The quoted line that drew our attention was this: “The loss of Ml due to external corrosion is the single biggest concern in industrial ammonia refrigeration components.”
We wondered – if OSHA is saying this in the course, what else are they saying? What was their source for this information? We again requested to be able to attend the course at our own cost and were turned down. GCAP’s Director of Compliance Services, Brian Chapin, recalled a court ruling that was referenced in the MEER decision (http://www.oshrc.gov/decisions/html_1997/95-0341.html) from the 1990’s from the Fifth Circuit Court of Appeals in Diamond Roofing v. OSHRC, 528 F.2d 645, 649 (5th Cir. 1976):
“An employer, however, is entitled to fair notice in dealing with his government. Like other statutes and regulations which allow monetary penalties against those who violate them, an occupational safety and health standard must give an employer fair warning of the conduct it prohibits or requires, and it must provide a reasonably clear standard of culpability to circumscribe the discretion of the enforcing authority and its agents….
If a violation of a regulation subjects private parties to criminal or civil sanctions, a regulation cannot be construed to mean what an agency intended but did not adequately express.”
We didn’t think that an OSHA course on how they interpret the standard could be refused under FOIA so we requested the coursebook from the course under the Freedom of Information Act. Jeremy Williams, Managing Director of GCAP stated: “They can’t rig the game like this – if we’re being held to certain standards, we should know what they are. Sure, this is a legal issue, but at the end of the day it’s about Process Safety – Safety being the key word here.”
Eventually OSHA approved our FOIA request and we received three books totaling about 500 pages.
Unfortunately, they had redacted quite a bit of the information we were actually interested in. One example is the Ammonia Refrigeration Processes and Equipment presentation which was of particular interest.
Slides that were redacted include titles like:
- Does PSM Apply?
- What About NH3 Refrigeration Processes < 10,000lbs?
- What are Signs of a Poor NH3 Refrigeration PSM Program?
- What Design Codes and Standards Could be Expected in PSI?
- Inspection RAGAGEP?
You can understand why we would want access to that information. OSHA had redacted it under provision 7(e) of the Freedom of Information Act. Provision 7(e) protects records or information compiled for law enforcement purposes the release of which could reasonably be expected to disclose techniques and procedures for law enforcement investigations or prosecutions. Essentially, they are arguing that if we knew what they were looking for we would be able to avoid citations.
Look, we at GCAP don’t necessarily disagree in that argument, but this same argument could be made to block any information requested about any citation at all! If they are looking for things because those things indicate a safety issue, then solving those things would alleviate the safety issue. Isn’t that what they are in business for? We don’t think citations should be the primary business that OSHA is in!
We’d rather have the problem solved by the PSM practitioner and refrigeration technicians to ensure the safety of the community and the employee BEFORE the odd OSHA inspection or chemical release. OSHA’s position seems to be that the information on these slides shows inspectors where there are gaps in a program but that information should only be known to the inspectors – not the people actually endangered by the process or the people in charge of ensuring its safety.
Is OSHA more interested in citations than employee safety? It certainly shouldn’t be – according to their own website (https://www.osha.gov/about.html) the reason that congress created OSHA was “to assure safe and healthful working conditions for working men and women by setting and enforcing standards and by providing training, outreach, education and assistance.”
Is hiding information that would show those operating a chemical process where there might be flaws in that process really how they intend to “assure safe and healthful working conditions for working men and women”? We at GCAP don’t think that’s right and we intend to appeal these redactions.
Look for an upcoming podcast where we discuss what we learned from the information they did provide including the answer to the original question: What was the source of that quote in the original citation?
By KELTON BROOKS
Residents of Garden City are more than familiar with the Lee Richardson Zoo and the 2.2 million gallon “Big Pool,” but not as well known to some in Garden City would be being home to the world’s largest industrial, hands-on technical school and training lab.
Along the winding road of Fulton Street, just before one hits the highway, stands a facility recognized as one of the premier programs of its kind in the United States.
The Garden City Ammonia Program provides training for more than 600 different companies and instructs about 1,800 to 2,000 students a year.
“We’re kind of like a two-year technical school, but instead of going to school for two years, they are coming in and taking week-long courses,” Jeremy Williams, directing manager of the Garden City Ammonia Program, said.
And by “they,” Williams is referring to the students who take observation tests and written exams to check their knowledge on operating the machinery.
The program has close to 40 people in Garden City per week, who take two to three classes a week.
“We train refrigeration technicians and managers on how to use refrigers such as ammonia, refrigeration processors, carbon dioxide and steam boilers,” Williams said.
“What they are learning here is how to operate — safely and efficiently — these industrial systems,” he said.
Williams added that most of the students already have a “mechanical aptitude” and work for corporations such as Nestle, Sara Lee and Tyson.
“We want to see if they can exceed and go to the next level and progressively build their careers,” he said.
GCAP works with students from all of over the world, with 90 percent of its enrollment by people outside the state of Kansas. This week, there are 13 people from different states and five people from different countries, ranging from Alaska to Australia.
“It’s a fantastic program here,” Alessandro Silva, 41, who arrived at the program Nov. 5 from Brazil, said. “In Brazil, we don’t have a program like this which motivated me to come here. Everything is put on the table very clear. I want to learn as much as I can here to provide information for my country and colleagues.”
Patrick Fossey, 35, a Venezuelan from Chile, said he was “very satisfied with the program and facility.”
“Everything here is conceived to teach,” Fossey said. “It is a facility where you will come and learn.”
Representative George Miller that has been in congress since 1975 has introduced legislation to revise the OSHA penalty structure. There are some interesting changes in this legislation that could tremendously affect our industry relating to fines and penalties.
Repeat Violations – Increased from $70,000 to $120,000
Serious Violations – OSHA has requested increase from $7,000 to $12,000.
Built in inflation adjustment for penalty amounts
Requirement of reporting of fatalities and hospitalizations of 2 or more employees (currently 3)
5 years imprisonment for a 1st offence violation that causes or contributes to serious bodily harm to any employee but does not cause death to any employee – 10 years for subsequent offences
10 years imprisonment for a 1st offence violation that causes or contributes to the death to any employee – 20 years for subsequent offences
Increases federal oversight of state OSHA plans
Increases whistle-blower protection
Allows multiple general duty citations – one for each affected employee
These would be massive changes to the enforcement of the OSHA rules.
You can read the bill at this link.
These videos may be considered to be old school, but they are great videos on basic refrigeration done by the US government.
Principles of Refrigeration
GCAP has been highly involved with PSM/RMP training and PSM/RMP compliance services the last decade.
Starting January 2014, we will start our Compliance Training Tour!
Look for Garden City Ammonia Program to come to a town near you.
January 27 – 30, 2014 @ Bakersfield, CA
February 24 – 27, 2014 @ Fort Worth, TX
March 3 – 6, 2014 @ Arnold, PA
March 17 – 20, 2014 @ Eau Claire, WI
March 31 – April 3, 2014 @ Fayetteville, AR
April 21 – 24, 2014 @ Phoenix, AZ
May 5 – 8, 2014 @ Auburn, MA
May 19 – 22, 2014 @ Springdale, OH
June 16 -19, 2014 @ Geneva, IL
July 28 – 31 @ Bakersfield, CA
GCAP is finalizing ten other locations.
If you would like to host one of these seminars please contact Kristen De La Pena of GCAP at 620-271-0037 or email@example.com
GCAP’s PSM/RMP Video
Garden City Ammonia Program has developed a 22 minute DVD specifically for PSM/RMP Ammonia Awareness. It is designed to give newly hired employees a brief overview of OSHA’s 29 CFR 1910.119 and also EPA’s risk management program from book 40. We are finding that the industry is hiring new employees that are not familiar with the requirements under these standards. In response to that trend, we created this DVD to give them an idea of what the standards and an introduction to PSM/RMP
I came across this video from SAFTENG.net
Not much is known on the accident but it was from Araguaina, Brazil and the language being spoken is Portuguese.